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Privacy Policy

HOWTOWINBREXIT.COM

In an attempt to ensure the best possible protection of your personal data, we would like to assure you that we protect your personal data at the highest level. In this document, you will find all the necessary information about what personal data we process and for what purpose.

1. Data Controller

The controller of your personal data is A. G. sp. z o.o. with its registered office in Warsaw (Poland) (00-765), ul. Piaseczyńska 71, entered in the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0000526327, NIP: 5223019507, REGON: 14746862800000, with a share capital of PLN 5,000.

In order to ensure the security of the data entrusted to us, we have developed internal procedures and recommendations to prevent data from being disclosed to unauthorized persons. We control their execution and constantly check their compliance with the relevant legal acts – GDPR, the Polish Act on Personal Data Protection of May 10, 2018, the Law on Provision of Electronic Services of July 18, 2002, as well as all kinds of regulations and EU acts.

2. How to contact the Company

If you have any questions or comments regarding data processing,

please contact:

via e-mail: info@howtowinbrexit.com
via mail: ul. Piaseczyńska 71, 00-765 Warsaw (Poland)

The request to correct or delete personal data should be reported to us at: info@howtowinbrexit.com.

3. What data do we collect and for what purpose?

The scope and purpose of our data collection depend on the extent of your interaction with us, including your use of the website at www.howtowinbrexit.com „Website„.

a) User data, which is collected automatically upon entering the Website

In order to enable rendering services and to protect copyrights, as well as for statistical and billing purposes, the Website processes data characterizing how usage of the services. For this purpose, Website’s server:

  • monitors the IP address from which the User connects,
  • collects statistical information about the visited websites.

The Website does not keep any information about the hardware configuration of the computer or programs installed on the User’s computer.

The IT system used by the Website automatically collects in the logs data related to the device used by the User when connecting to the Website. This data is collected only for statistical purposes and relates to: the type of device, operating system, type of Internet browser, screen resolution, color depth, IP address, internet service provider, or the address of entry to the Website, and is used only in the process of optimizing the Website in order to ensure the greatest possible comfort of use, which constitutes our legitimate interest.

This data is never combined with other data and is only material for statistical analysis and system error correction mechanisms.

b) Data of persons participating in the events organized by the Controller, including gameplays and promotional gameplays;

We process the personal data of persons participating in the events organized by us, including gameplays and promotional gameplays such as: name, last name, e-mail address, telephone number, address, data necessary for barter settlement, social media profile name, for the following purposes:

  • to comply with legal obligations imposed on the Controller, resulting in particular from tax regulations – the legal basis for processing is compliance with a legal obligation;
  • possible establishment, investigation, or defense against – the legal basis for processing is the legitimate interest in protecting our rights;
  • marketing of the Controller’s own products and services – the legal basis for processing is our legitimate interest consisting of direct marketing of our own products and services in connection with the consent given by the participant;
  • in case of separate consent for the processing of data including image or social media profile name – the legal basis for processing is the given consent;

c) Personal data of those who contact us by e-mail;

When you contact us via e-mail, you simultaneously provide us with your e-mail address as the sender of the message. In addition, you may also include other personal information in the message. You may be asked by us to provide additional data only if it is necessary to provide service to the subject of the contact. The legal basis in such a case is our legitimate interest in connection with the consent given, based on the necessity to resolve the notified matter related to the service and possible investigation and defense against potential claims.

d) Personal data of supporters of the project on Kickstarter Service;

If you are among the supporters of our project on Kickstarter, we process your data, such as your username, amount of declared support, delivery address, selected prize and any additional information related to the selected prize, for the following purposes:

  • performance of the contract (including the processing of any complaints) – the legal basis for processing is the necessity of processing to perform the contract;
  • possible establishment, investigation, or defense against claims and for the performance of the contract concluded with the customer – the legal basis for processing is the legitimate interest of protecting our rights;

e) Newsletter subscribers;

In the event that you provide us with your name and e-mail address for this purpose, we provide you with newsletter services, i.e. the delivery of commercial information regarding the products or services we offer. Providing this data is voluntary, but necessary to receive the newsletter.

Personal data is processed:

  • in the case of sending marketing content within newsletter service – the legal basis for processing, is the legitimate interest;
  • for possible establishment, investigation, or defense against claims – the legal basis for processing is the legitimate interest of protecting our rights.

f) Data of users of social media profiles.

Our social media profiles are public. When you visit our profile, you provide us with your personal data (e.g., account name, comments, likes, web IDs, and the IP address of the device you are using).

This data is processed in order to: (i) to enable us to effectively operate our profile on a particular site or application in connection with our promotion of a variety of events, services, and products, and (ii) to communicate with users. The legal basis for the processing of personal data is our legitimate interest in promoting our brand, improving the quality of our services, and ongoing communication with fan page users.

NOTE: the above information does not apply to the processing of your personal data by the administrators of given social media websites.

g) Personal data of individuals who are:

  • customers,
  • subcontractors;
  • suppliers;
  • partners of the Controller; or
  • persons representing the Controller’s customers; and
  • persons designated to contact the Controller

If you belong to one of the categories indicated above, we process your data for the following purposes:

  • performance of the contract (including the processing of any complaints) – the legal basis for its processing is the necessity of processing to perform the contract;
  • to perform legal obligations imposed on the Controller, resulting in particular from tax and accounting regulations, consisting, among others, in the necessity to issue or settle an invoice or other accounting documents and their archiving – the legal basis for processing is the legal obligation;
  • possible establishment, investigation, or defense against claims – the legal basis for processing is the legitimate interest of protecting our rights;
  • proper performance of a concluded contract- the legal basis for processing is the legitimate interest of protecting our rights;
  • personal data of persons authorized to represent you are processed in order to identify them for the purposes of drafting and proper conclusion of a contract – the legal basis for processing is the legitimate interest of drafting and proper conclusion of a contract;
  • personal data of designated contact persons are processed in order to maintain contact during the performance of the contract – the legal basis for processing is the legitimate interest consisting in the proper performanceof concluded contracts;

h) Personal data of persons who are potential customers;

We process potential customers’ data, including name and contact information, in order to:

  • to offer our services, which is our legitimate interest;
  • for the purpose of possible establishment, investigation, or defense against claims – the legal basis for processing is the legitimate interest of protecting our rights;

4. How long does the Controller processes personal data?

The period of data processing depends on the type of service provided and the purpose of processing. As a rule, data are processed:

(a) for the duration of the service rendering or performance of other agreements;

(b) until the withdrawal of a given consent;

(c) until an effective objection is made;

(d) until an effective request for the erasure of data is made.

The period of data processing may be extended if the processing is necessary for the establishment, investigation, or defense against possible claims, and after this period, only if and to the extent required by law.

5. What rights do the customers have with regard to their personal data?

We guarantee the exercise of all the rights of those whose data we process, including the right:

  • of access to the data, including obtaining a copy;
  • to rectification of data;
  • to the erasure of data;
  • to restriction of processing;
  • to data portability;
  • withdrawal of consent at any time (which does not affect the lawfulness of processing based on consent before its withdrawal);
  • to object;
  • to file a complaint to the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193 Warsaw).

If you wish to exercise your rights, please contact us in the first place.

6. To whom is personal data disclosed

Personal data on the basis of relevant contracts are transferred to entities that process data on behalf of the Controller, i.e. an accounting firm. Such entities process the data only in accordance with our instructions, maintaining its confidentiality and security. We have the right to control how the data entrusted to us is processed.

In other cases, personal data may be disclosed to entities authorized only by law.

7. Transfer of data outside the EEA

The Controller transfers personal data outside the EEA in the course of using subcontractors such as Microsoft Corporation or Alphabet, Inc. We make efforts to ensure an adequate level of protection of personal data, after careful consideration of the data security offered by the subcontractors. The transfer of data is based on standard contractual clauses approved by the European Commission.

We also reserve the possibility of transferring data from personal social media plug-ins, as stated in Section 8. „Social media” and in the use of our partners’ tools, as stated in Section 10. „Our partners’ tools”.

8. Social media

The Service uses plug-ins and other social networking tools provided by social media websites.

In connection with the use of the Website, which includes such a plug-in, your browser establishes a direct connection to the servers of the social media administrators (service providers). The content of the plug-in is transmitted by the relevant service provider directly to your browser and integrated into the Website. Thanks to this integration, the service providers receive information that your browser has displayed on the Website, even if you do not have a profile with the given service provider or are not currently logged in. This information (along with your IP address) is sent by your browser directly to the service provider’s server (some servers are located in the USA) and stored there.

If you have logged in to a social network, this service provider will be able to directly associate your visit to the Website with your profile on the given social network. If you use a particular plug-in, such as the „Like” button, then the corresponding information will also be sent directly to the server of the respective service provider and stored there. In addition, this information will be published on the respective social network and will appear to the people added as your contacts. 

The purpose and scope of data collection and their further processing and use by the service providers, as well as the possibility of contacting you and your rights in this regard and the possibility to make adjustments to ensure the protection of your privacy are described in the privacy policies of the respective service providers.

If you do not want social media websites to assign the data collected during your visit to the Website directly to your profile on a particular service, it is necessary to log out of that service before visiting the Website. It is also possible to prevent plug-ins from loading on the Websites altogether by using appropriate extensions for your browser, such as blocking scripts.

9. Cookie policy

The Website uses so-called cookies as part of your use of the Website. These are small text files placed on your devices (e.g. computers) via web browsers. These files allow certain information to be stored on your device and then read by the service that created the files. Cookies usually contain, in addition to the domain name of the website from which they originate, the time they are stored on your terminal device, and a unique number.

Cookies are used by us for:

a) adjusting the content of the websites to the individual preferences of the User and optimizing the use of the websites by the User (cookies allow, in particular, to recognize your device and the appropriate display of the website, so that it is best adapted to individual needs);

b) to create statistics (so that we can better understand how the Users of our website use the websites, and consequently we can improve the structure and the content of these websites);

The service does not store any information about the computer’s hardware configuration or programs installed on the computer.

Changing cookie settings:

Usually, the User’s web browser allows the storage of cookies on the User’s terminal device by default. However, at any time Users of the website have the ability and right to change their cookie settings. In order to change the settings of cookies, Users should read detailed information about the possibilities and ways of handling cookies, which are available in the settings of their web browser.

If the User does not agree to the placement of cookies on his/her device, he/she can block their placement by configuring his/her web browser accordingly. He will find information on how to do this in the help files of his web browser. Unfortunately, if you block cookies from the Service, we cannot guarantee its correct operation. If the User does not change his/her cookie settings, these files will be placed on the User’s terminal device. This means that we will store information on the User’s final device and access this information.

10. The tools of our partners

In order for us to provide our services and improve and analyze them, we also rely on the services and tools of other entities. These entities perform only for the purposes specified by us. Below is information about our partners and the tools they use.

  • Google Analytics: We use Google Analytics, an analytics tool provided by Google Ireland Limited („Google”) based in Ireland. As part of this feature, we use cookies to track site statistics, such as the number of visitors, the type of operating system and browser used to browse the site, the time spent on the site, the sub-pages visited, and to obtain and analyze information regarding, among other things, the effectiveness of our marketing campaigns or the time spent on the website. We use this information only to improve the quality of the site.
  • We use reCAPTCHA service tool provided by Google Ireland Limited („Google”) based in Ireland in order to protect our Website from spam and abuse. This tool allows determining if a given User of the Website is human or a bot to detect and prevent abusive traffic.

11. Modification of privacy policy

The Privacy Policy is continuously reviewed and updated as necessary. The current version of the Privacy Policy has been adopted and is in force as of February 2nd, 2023.